No Time Limit with ERISA Benefits Claims

After a long legal battle that was supposed to dispute the previous decision made by a U.S. District Court judge, Dionisio Santana-Díaz has achieved his goal. Judge O. Rogeriee Thompson, who was one of three judges at the 1st U.S. Circuit Court of Appeals’ panel announced that the entire panel unanimously arrived at the same conclusion – the fact that the last denial letter didn’t clearly point out the time limitation for filing suit is enough to make the U.S. District Court judge’s initial ruling illegitimate. This will allow Dionisio Santana-Díaz to continue his fight for disability benefits and take it a step further.

The History of the Case

Dionisio Santana-Díaz worked as a financial analyst for Shell Chemical Yabucoa. He was included in the well-fare plan that was a part of his contract and it was supposed to be delivered through Metropolitan Life Insurance Co. In November of 2007, Santana-Díaz first received a sick leave, and then filed for short-term disability leave. He suffered from high-blood pressure, depression, and other physical and mental illnesses. Therefore, his disability leave was completely justified and he filed for a long-term one in 2008. He was granted the benefits.

Santana-Díaz was notified in April of 2010 that even though he is currently receiving the benefits, they will be stopped after exactly twenty-four months since they were approved. Therefore, his long-term disability benefits will not continue to arrive after November 2010. Santana-Díaz immediately replied to the letter with his own claim, attaching his medical records and other documents as a proof that his benefits should be extended due to the fact that his health is still bad and he is not able to support himself financially without the disability benefits.

His plea was denied in November, so he tried filing an administrative appeal which was also rejected by the defendant. The letters did include the information that Santana-Díaz is free to file a civil suit, but there was no mention of either a particular time limitation, or that he has to do that urgently. Unfortunately, Santana-Díaz waited until August of 2013 to file the suit and the judge easily decided that the defendant has all the rights to stop providing the disability benefits since the time limit was reached. Santana-Díaz was not informed about any time limitation so he was shocked with the judge’s decision. Luckily, he did not give up.

The Ruling

This case ended up being reviewed by the 1st U.S. Circuit Court of Appeals and the judges decided that Santana-Díaz should have been informed about the time limitation, either in the letters or by some other means of communication. The defendant did not provide all the necessary information to Santana-Díaz, and therefore, the initial ruling is not valid. Metropolitan Life Insurance Co was supposed to provide Santana-Díaz with all the details, giving him a chance to prepare his case in time, and file a suit within the time limit. Since they left the time limitation from both of their letters which is a sign of terrible communication within that company, they clearly violated ERISA regulations.

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